ppc plans

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Jim Kline

Mineral Resources Program Specialist

DEP- Bureau of Oil and Gas Management

[email protected]

(814)472-1903

PPC PLANS

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Theseevents would nothave occurred ifaTheseevents would nothave occurred ifaPPC Plan was developed and implemented!!!PPC Plan was developed and implemented!!!

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What isa PPCWhat isa PPC??

PPC stands for :PPC stands for :

PPreparednessreparedness

PPreventionrevention CContingencyontingency

Purpose: To improve and preserve the purity of the Watersof the Commonwealth by prompt adequate response to allemergencies and accidental spills of polluting substancesfor the protection of public health, animal, aquatic life andfor recreation.

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PPC Plans and Oil & GasPPC Plans and Oil & Gas

Development in PennsylvaniaDevelopment in Pennsylvania

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Develop and implement your PPC plan,Develop and implement your PPC plan,

or you will have to deal with what couldor you will have to deal with what could

happenhappen

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PPC ObjectivePPC Objective

To consolidatethesimilarities ofthe Stateand Federalpollution incident preventionand emergency responseprograms into one overall program.

Industrial and commercial installations whichhavethepotential for causingaccidental pollution ofair, land orwater, or theendangerment of public healthand safety

are required to develop and implementa PPC planwhichencompassthe other Departmental programrequirements ..

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PPC plans in regards to Oil and GasPPC plans in regards to Oil and Gas

Operations in PennsylvaniaOperations in Pennsylvania

Required under the Clean Streams Law for approval of:Required under the Clean Streams Law for approval of:

Road spreading operationsRoad spreading operations Drilling and operating oil and gas wells,Drilling and operating oil and gas wells, Brine disposal wells.Brine disposal wells.

These plans are required under 25 Pa. Code ChaptersThese plans are required under 25 Pa. Code Chapters91.34 and 78.55 (Water Resources and Oil & Gas).91.34 and 78.55 (Water Resources and Oil & Gas).

PPC Plans are required for NPDES and Part II WaterPPC Plans are required for NPDES and Part II WaterQuality Management Permits.Quality Management Permits.

The Plan requirements are contained in the Oil and Gas OperatorsThe Plan requirements are contained in the Oil and Gas OperatorsManual. (Chapter 4, Section 1)Manual. (Chapter 4, Section 1)

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Guidelines for a PPC Plan for OilGuidelines for a PPC Plan for Oil

and Gas Developmentand Gas Development The operator must reviewtheir operationsand identifyThe operator must reviewtheir operationsand identify

all ofthe pollutional substancesand wastes (solid andall ofthe pollutional substancesand wastes (solid andliquid) that will be used or generated.liquid) that will be used or generated.

The operator then must develop control methods.The operator then must develop control methods.

The operator must recognizethataccidentsandThe operator must recognizethataccidentsandunexpected conditions may occur and immediateunexpected conditions may occur and immediate

response would benecessaryto prevent pollution fromresponse would benecessaryto prevent pollution fromreachingthe waters ofthe Commonweathreachingthe waters ofthe Commonweath

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The 6 ELEMENTS of a PPC PLAN

1. Description ofthe operation1. Description ofthe operation

2. Description of Pollution Prevention Measures2. Description of Pollution Prevention Measures

3. Waste Disposal Methods3. Waste Disposal Methods4. Pollution Incident Response4. Pollution Incident Response

5. Narrative Section5. Narrative Section

6. PPC Schedule6. PPC Schedule

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The most important part of a PPCThe most important part of a PPC

plan is..plan is..THE ACTUAL EFFECTIVENESSTHE ACTUAL EFFECTIVENESS

Based upon:Based upon:

SimplicitySimplicity

ReadabilityReadability

ResourcesResources

RehearsalsRehearsals

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ELEMENTS AND FORMAT OF A

PPC PLAN1. Description ofthe Operation

Identifythetype of operations (Oil, Gas or both).Identifythetype of operations (Oil, Gas or both).

Describethe method of drillingthe wells (air rotary,Describethe method of drillingthe wells (air rotary,fluid rotary, cabletool, etc).fluid rotary, cabletool, etc).

Identifyeach well location by lease, farm name,Identifyeach well location by lease, farm name,

project or other distinguishable description.project or other distinguishable description.

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PPC PLAN2. Description of the Pollution Prevention Measures

Listthe chemicals or additives utilized and the different wastesListthe chemicals or additives utilized and the different wastesgenerated duringthe drilling, stimulation, production, plugginggenerated duringthe drilling, stimulation, production, plugging

and servicing phase ofthe operation.and servicing phase ofthe operation. Includesafetyand health information (MSDS) cleanup protocol.Includesafetyand health information (MSDS) cleanup protocol. Anassessment ofthe likelihood & consequences ofanevent Method of containmentand contingency planning Protection from external factors (mother nature, 3rd parties) Preventive maintenance Security Training Programs

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PPC PLAN3. Waste Disposal Methods

Material Compatibility

Inspectionand Monitoring Program

Housekeeping Program

Name ofall permitted disposal facilities (solidsandliquids)

Types of wastesthatthe disposal facilities canaccept

Hauler information

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PPC PLAN4. Pollution Incident Response

Countermeasuresto be undertaken bythe Operator

Countermeasuresto be undertaken by Contractors

Internal and External Communicationsand AlarmSystems

Evacuation Plan for Personnel

EmergencyEquipment Available for Response

Reporting Procedures

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Reporting Procedures

Arrangements with Local Emergency ResponseAgenciesand Hospitals

These agencies must includeThese agencies must include::

DEP Regional office (both businessand 24DEP Regional office (both businessand 24--hour phonenumbers)hour phonenumbers) EPA Nation Response Center phonenumberEPA Nation Response Center phonenumber

Identifyand Contact downstream water usersIdentifyand Contact downstream water users

Recommended to contactthe PA Fishand Boat Commission (closestRecommended to contactthe PA Fishand Boat Commission (closestdistrict office)district office)

Notification Lists Downstream Notification Requirement for StorageTanks

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PPC PLAN5. Narrative section Arrangements with Local Emergency Response

Agenciesand Hospitals

Theseagencies must include:Theseagencies must include: DEP Regional office (both businessand 24DEP Regional office (both businessand 24--hour phonenumbers)hour phonenumbers) EPA Nation Response Center phonenumberEPA Nation Response Center phonenumber Identifyand Contact downstream water usersIdentifyand Contact downstream water users Recommended to contactthe PA Fishand Boat Commission (closestRecommended to contactthe PA Fishand Boat Commission (closest

district office)district office)

Notification Lists Downstream Notification Requirement for StorageTanks

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PPC PLAN

6. PPC Schedule6. PPC Schedule A copy ofthe planand anysubsequent revisions must be maintained on-site.

All members ofthe installations organization for developing, implementing, andmaintainingthe planand all emergency coordinators must reviewthe planand bethoroughly familiar withall provisions.

Inadditionto thesite copyand the copysubmitted to the Department, additionalcopiesshould be madeavailableto the followingagencies(to theextent whichthey may become involved inanactual emergency):

Countyand local Emergency Management Agencies (This isa legal requirement for storagetank facilities with >21,000 gallons ofabove ground storage).

Local Fire Service Agenciesand/or HazmatTeam

Local Emergency Medical Service Agencies

Local Police

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PPC Plan RevisionsThe PPC Plan must be periodically reviewed and updated.

At a minimum, this must occur when:

The Plan fails in an emergency

The installation changes in design, construction, operation,maintenance, or other circumstances in a manner that materiallyincreases the potential for fires, explosions or releases of toxic orhazardous constituents, or which changes the response necessary in anemergency

The list of emergency coordinators changes

The list of emergency equipment changes

As applicable Department Regulations are revised

As required by the Department.

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PPC Plan Questions?PPC Plan Questions?

Christopher TersineChristopher Tersine

[email protected]@state.pa.us

717-783-4409

ppc plans

Documents

Transcript of ppc plans